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Category:Legal-Pleading
MONTHYEARML23237B4152023-08-25025 August 2023
Constellation'S Answer Opposing CPS Energy'S and Austin'S Petition for Leave to Intervene and Hearing Request
ML23237B4242023-08-25025 August 2023
Nrg'S Answer Opposing the City of San Antonio'S and City of Austin'S Petition to Intervene and Supplemental Contention
ML23237B4252023-08-25025 August 2023
Exhibit a to Nrg'S Answer Opposing the City of San Antonio'S and City of Austin'S Petition to Intervene and Supplemental Contention
ML23237B4492023-08-25025 August 2023
Exhibit a to Nrg Answer Opposing the City of San Antonio and City of Austin'S Petition to Intervene and Supplemental Contention
ML23227A1022023-08-15015 August 2023
Non-Disclosure Declaration of Christine Zoino
ML23227A1012023-08-15015 August 2023
Non-Disclosure Declaration of Michelle Goldis
ML23227A1032023-08-15015 August 2023
Certificate of Service of Declarations of C. Zoino and M Goldis
ML23227A0232023-08-14014 August 2023
Resubmission of Exhibits a and B
ML23227A0172023-08-14014 August 2023
Non-Disclosure Declaration of David Lewis
ML23227A0212023-08-14014 August 2023
Non-Disclosure Declaration of D Zahn
ML23227A0222023-08-14014 August 2023
Certificate of Service for Nrg Non-Disclosure Declarations
ML23226A2732023-08-14014 August 2023
Certificate of Service for Non Disclosure Declaration of James Barkley
ML23227A0202023-08-14014 August 2023
Non-Disclosure Declaration of Christina Dillard
ML23227A0262023-08-14014 August 2023
Certificate of Service of Non-Disclosure Declaration of Thomas Farrell
ML23227A0192023-08-14014 August 2023
Non-Disclosure Declaration of Mitchell C Lancaster
ML23227A0182023-08-14014 August 2023
Non-Disclosure Declaration of Edmund Daniels
ML23227A0252023-08-14014 August 2023
Non-Disclosure Declaration of Thomas Farrell
ML23226A2722023-08-14014 August 2023
Non Disclosure Declaration of James Barkley
ML23223A2072023-08-11011 August 2023
CPS Energy Non-Disclosure Declarations
ML23220A2142023-08-0808 August 2023
Errata to Nrg'S Answer Opposing the Motion by the City of San Antonio and the City of Austin to Dismiss or Suspend License Transfer Proceeding
ML23219A2162023-08-0707 August 2023
STPNOC Answer Opposing Motions to Dismiss and Stay by CPS Energy and Austin
ML23216A1422023-08-0404 August 2023
Constellation'S Response in Opposition to Motion to Dismiss License Transfer Application and Motion for Stay
ML23216A1822023-08-0404 August 2023
Nrgs Answer Opposing the Motion by the City of San Antonio and the City of Austin to Dismiss or Suspend License Transfer Proceeding
ML23216A1952023-08-0404 August 2023
Revised Signature Page for Constellation'S Response
ML23215A0242023-08-0303 August 2023
Notice of Appearance of David R Lewis
ML23212B2442023-07-31031 July 2023
Notice of Appearance of M. Stanford Blanton for CPS Energy Counsel
ML15127A2532015-05-0707 May 2015
Reply by Beyond Nuclear, Blue Ridge Environmental Defense League, Nuclear Information and Resource Service, Seed Coalition and Southern Alliance for Clean Energy to Oppositions by Applicants and NRC Staff to Motions to Admit New Contentions
ML15127A2512015-05-0707 May 2015
Reply by Beyond Nuclear, Blue Ridge Environmental Defense League, Nuclear Information and Resource Service, Seed Coalition and Southern Alliance for Clean Energy to Oppositions by Applicants and NRC Staff to Motions to Admit New Contentions
ML15126A4782015-05-0606 May 2015
Reply by Beyond Nuclear, Blue Ridge Environmental Defense League, Nuclear Information and Resource Service, Seed Coalition and Southern Alliance for Clean Energy to Oppositions by Applicants and NRC Staff to Motions to Admit New Contentions
ML15124A7832015-05-0404 May 2015
STP Nuclear Operating Company Response Opposing Motion to Reopen and Placeholder Contention Regarding Continued Storage Rule
ML15121A7502015-05-0101 May 2015
NRC Staff Answer to Seed Coalitions Hearing Request and Petition to Intervene and Motion to Reopen the Record in the License Renewal Proceeding for South Texas Units 1 and 2
ML15114A4562015-04-24024 April 2015
Declaration of Susan Dancer
ML15049A6472015-02-18018 February 2015
Petitioners' Reply to Oppositions to Petition to Supplement Reactor-Specific Environmental Impact Statements to Incorporate by Reference the Generic Environmental Impact Statement for Continued Spent Fuel Storage
ML15043A7882015-02-12012 February 2015
NRC Staff Opposition to the Petition to Supplement Reactor-Specific Environmental Impact Statements to Incorporate by Reference the Generic Environmental Impact Statement for Continued Spent Fuel Storage.
ML15043A4672015-02-12012 February 2015
STP Nuclear Operating Company Response Opposing Petition to Supplement Environmental Impact Statements
ML15033A4872015-01-29029 January 2015
Petition to Supplement Reactor Specific Environmental Impact Statements to Incorporate by Reference the Generic Environmental Impact Statement for Continued Spent Fuel Storage
ML14311A9832014-11-0707 November 2014
Petitioners' and Intervenors' Consolidated Reply to Answer to Petitions to Suspend Final Reactor Licensing Decisions, Motions to Admit a New Contention, Motions to Reopen the Record
ML14304A7192014-10-31031 October 2014
STP Nuclear Operating Company Combined Response to Proposed Contention and Petition to Suspend Related to Alleged Need for Issuance of Waste Confidence Safety Findings
ML14304A7152014-10-31031 October 2014
NRC Staff Consolidated Answer to Petitions to Suspend Final Reactor Licensing Decisions, Motions to Admit a New Contention, and Motions to Reopen the Record
ML14304A6652014-10-31031 October 2014
NEI Motion and Amicus Brief in the Matter of STP Nuclear Operating Co. (South Texas Project, Units 1 and 2)
ML14302A7832014-10-29029 October 2014
Notice of Appearance of Mitzi A. Young
ML14301A4292014-10-28028 October 2014
Notice of Appearance of Anita Ghosh
ML13130A3782013-05-10010 May 2013
Notice of Withdrawal of Appearance from Maxwell C. Smith
2023-08-08
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Text
April 4, 2015 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY OF THE COMMISSION In the Matter of )
) Docket Nos. 50-498-LR, SOUTH TEXAS PROJECT ) 50-499-LR NUCLEAR OPERATING CO. )
(South Texas Project Units 1 and 2) )
)
DECLARATION OF SUSAN DANCER Under penalty of perjury, I, Susan Dancer, declare as follows:
- 1. I make this declaration of my own personal knowledge. If called to testify as a witness, I could and would testify competently regarding its contents.
- 2. I am a current member of SEED Coalition. I agree with SEED Coalitions mission of working for clean air and clean energy in Texas, and protecting the public from risks of radioactive contamination. I believe my health and well-being depend upon the health of the environment in the region where I live. I have authorized SEED Coalition to submit a contention on my behalf challenging the NRCs failure to fully and adequately assess the environmental impacts of storing and disposing of the spent fuel that will be generated by the South Texas Project Units 1 and 2 nuclear reactors, if the license is renewed.
- 3. I know that SEED Coalition submitted comments to the U.S. Nuclear Regulatory Commission (NRC) in 2013 regarding the NRCs proposed rule entitled Waste Confidence Decision - Continued Storage of Spent Nuclear Fuel, which was published at 78 Fed. Reg.
56,776 on September 13, 2013 and its accompanying Waste Confidence Generic Environmental Impact Statement, published the same day.
- 4. I live at 648 County Road 475, Blessing, Texas 77419. My home lies within 18 miles of the proposed South Texas Project Units 1 and 2 nuclear reactors. This is less than the fifty-mile radius distance at which the U.S. Nuclear Regulatory Commission (NRC) presumes a reactor accident will cause harm to my health and safety.
- 5. I am concerned about the health and environmental risks posed by the spent fuel that will be generated by South Texas Project Units 1 and 2 if the license is renewed. I am aware that Congress has established a policy that the spent fuel should be removed from the South Texas Project Units 1 and 2 nuclear plant site to a repository for permanent disposal. But, I am concerned that permanent disposal of spent fuel may not be feasible. I am also concerned that the government will not find sufficient capacity in a repository or multiple repositories to 1
accommodate the spent fuel to be generated by South Texas Project Units 1 and 2. For these reasons, I am concerned that the South Texas Project Units 1 and 2 reactor site may become a de facto long term spent fuel storage depot or even waste disposal site. I am concerned that spent fuel stored for a lengthy period at the South Texas Project Units 1 and 2 site may leak into the environment and harm my health and threaten my safety. Additionally, I am concerned about the health and safety of future generations in my family, and protection of the environment.
- 6. I am aware that NRC must conduct a full environmental review whenever it licenses or re-licenses a nuclear power plant. However, I am concerned that NRC has not adequately evaluated the environmental, health, and safety consequences of storing spent nuclear fuel at the South Texas Project Units 1 and 2 nuclear plant site during the time following the licensed life of the reactor. In the absence of adequate environmental analyses regarding the storage of spent fuel, I do not have confidence that my health and safety or the integrity of my environment will be protected from the adverse effects of exposure to spent reactor fuel.
- 7. I have authorized SEED Coalition to file a contention that seeks to raise my concerns in this proceeding. I believe this contention will redress my concerns by forcing the NRC to either conduct the required environmental analyses or deny the license application for South Texas Project Units 1 and 2.
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I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information and belief.
Susan Dancer April 4, 2015 3
